What changed
The UN Security Council's 1267/1989 Committee released updated Al-Qaida sanctions lists covering the twentieth to thirtieth updates. RBI has directed all NBFCs to incorporate these updates into their customer screening processes, referencing a previous circular from October 3, 2013.
What it means for you
NBFCs must immediately update their internal databases with the new UN sanctions list to avoid onboarding or servicing prohibited entities. Non-compliance could lead to regulatory action. This reinforces the need for robust AML/KYC frameworks in the NBFC sector.
What you must do
- Download the updated Al-Qaida sanctions list from the provided UN URLs and integrate it into your customer screening system.
- Screen all new account applications against the updated list before account opening.
- Conduct a retrospective scan of all existing customer accounts to identify any matches with the updated list.
- Ensure no account is held by or linked to any entity or individual in the list.
Who it affects
All Non-Banking Financial Companies (NBFCs), Residuary Non-Banking Companies (RNBCs), Compliance and AML/KYC teams at NBFCs
What is the legal basis for this circular?
This circular is issued under Section 51-A of the Unlawful Activities (Prevention) Act, 1967, which empowers RBI to direct NBFCs to implement UN Security Council sanctions lists.
Where can I find the updated sanctions list?
The updated Al-Qaida sanctions list (twentieth to thirtieth updates) is available on the UN website at the URLs provided in the circular, including http://www.un.org/sc/committees/1267/aq_sanctions_list.shtml.
What should I do if I find a customer on the list?
Ensure the account is not held by or linked to any entity or individual in the list. The source does not specify further actions.